Epstein Secrets

provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w

ch re Travel for Prostitution" containing attorney (Villafafta) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury inf

serted Victims' Objections Box #3 Folder entitled "Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel" containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in A

of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att

net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00179621

uthorized release; Material Severable Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate

"Victim Civil Suits" Not privileged. Produced to counsel for Petitioners N/A Box #1 P-003664 Thru P-003678 File folder entitled "Research it JE Websites" containing attorney research Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation;

re Travel for Prostitution" containing attorney (Villafaria) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury i

ecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013836 Thru P-013837 Palm Beach Daily News Article, "Attorneys want Jeffrey Epstein Agreement Thrown Out," with attorney's notes written on margin Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty;

recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey E stein Investi ation Attorney-Client Privilege Deliberative Process Work Product No Factual Underpinnings; Fiduciary Duty; Not in Anticipation

uthorized release; Material Severable Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not parties to this litigation Inadequate

JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant I REPLY TO JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is not timely because they firs

O JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is not timely because they first filed their discovery requests more than a year and a half ago. Response at 3-4. Tha

E DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION In their Respon

In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is not timely beca

Number One in Support of United States' Response to Motion to Quash Subpoenas"); 20 ("Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas," "Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash," indictment preparation materials); 21 (

d States of America, by and through the undersigned Assistant United States Attorney, hereby moves to seal this Motion, the United States' Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel , the United States' Motion for Permission to File Ex Pane Affidavits, th

this Motion, the United States' Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas a

to seal this Motion, the United States' Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

rey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel, Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas, the Declaration of and the Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas for the following re